Laura Julin v. Carolyn W. Colvin
2016 U.S. App. LEXIS 11567
| 8th Cir. | 2016Background
- In Dec 2009 Laura Julin applied for disability insurance (Title II) and supplemental security income (Title XVI), alleging depression, anxiety, and OCD with onset Feb 15, 2004; she later pursued SSI only for period after Dec 21, 2009.
- SSA denied benefits; after an ALJ hearing (2011) and Appeals Council remand for further consideration of Dr. Welsh (treating physician) and residual functional capacity (RFC), a second ALJ hearing (2013) again denied benefits; Appeals Council denied review and district court affirmed.
- ALJ found severe mental impairments (major depressive disorder, dysthymia, anxiety, OCD, history of marijuana use) but not meeting listings, and assessed an RFC allowing all exertional levels with nonexertional limits: simple tasks learnable within 30 days, few work-place changes, no production pace, and only occasional/brief/superficial interactions.
- The ALJ discounted Julin’s credibility based on: equivocal objective medical evidence; long gaps and sporadic pretreatment work history; daily activities inconsistent with total disability; medication effectiveness and refusal of some treatment/therapy; inconsistent statements to providers; and statements indicating motivation to obtain disability.
- The ALJ gave limited weight to some of Dr. Welsh’s opinions (including a conclusory opinion that Julin could not work full time) because they were partly based on Julin’s subjective reports and were conclusory; the ALJ relied also on state-agency consultants and independent review to support the RFC.
- The Eighth Circuit affirmed, holding the ALJ’s credibility finding, evaluation of treating-source opinions, and RFC determination were supported by substantial evidence and that no further medical development was required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred in discounting claimant credibility | Julin: ALJ failed to apply Polaski factors and lacked substantial evidence to discredit her symptom testimony | Commissioner: ALJ considered objective evidence, daily activities, treatment gaps, medication effectiveness, inconsistent statements, and noncompliance; substantial evidence supports credibility finding | ALJ credibility determination upheld; substantial evidence supports discounting Julin’s subjective complaints |
| Whether ALJ improperly failed to give treating physician Dr. Welsh controlling weight | Julin: Dr. Welsh’s opinions require controlling weight and support greater limitations | Commissioner: Dr. Welsh’s opinions were conclusory, relied on claimant’s subjective reports, and were inconsistent with record; ALJ permissibly assigned limited weight | ALJ permissibly gave limited (but not no) weight to Dr. Welsh’s opinions; controlling weight not required |
| Whether medical evidence supports the RFC | Julin: Without controlling weight for Dr. Welsh, no substantial medical support for RFC limits | Commissioner: RFC based on Dr. Welsh’s nonconclusory findings, state-agency consultants, and ALJ’s independent review | RFC supported by substantial evidence; ALJ not required to obtain more records |
| Whether ALJ should have sought additional medical evidence | Julin: Additional testing or records needed to assess work-related limitations | Commissioner: Existing record (treating notes, consult reviews) was adequate; ALJ fulfilled duty to develop record | No duty to further develop record; ALJ’s choice to rely on available evidence upheld |
Key Cases Cited
- Bowen v. Yuckert, 482 U.S. 137 (Sup. Ct.) (framework for SSA disability evaluation)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating claimant subjective complaints)
- Guilliams v. Barnhart, 393 F.3d 798 (8th Cir. 2005) (deference to ALJ credibility findings when supported by good reasons and substantial evidence)
- Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (limits on relying on treating opinions that rest on claimant’s subjective complaints)
- Krogmeier v. Barnhart, 294 F.3d 1019 (8th Cir. 2002) (ALJ may conduct independent review of medical evidence when weighing opinions)
- McCoy v. Astrue, 648 F.3d 605 (8th Cir. 2011) (ALJ not always required to obtain additional medical evidence if record is adequate)
- Papesh v. Colvin, 786 F.3d 1126 (8th Cir. 2015) (treating physician opinions may be discounted if conclusory or inconsistent)
- Chaney v. Colvin, 812 F.3d 672 (8th Cir. 2016) (credibility and substantial-evidence review principles)
- Pearsall v. Massanari, 274 F.3d 1211 (8th Cir. 2001) (sporadic work history relevant to credibility)